郭文贵破产案 · ORDER · ECF #1617

## **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**

In re:

Chapter 11

HO WAN KWOK, *et al.*

Debtors.

Case No: 22-50073 (JAM)

## **HK INTERNATIONAL FUNDS INVESTMENTS (USA) LIMITED, LLC'S AND MEI GUO'S MOTION TO CONTINUE STATUS CONFERENCE**

HK International Funds Investments (USA) Limited, LLC ("HK USA") and Mei Guo, by and through their undersigned counsel, respectfully move for a continuance of the status conference scheduled for 1:30 pm on March 30, 2023 (the "Status Conference") to any time on March 31, 2023. HK USA and Ms. Guo state that good cause exists to grant the requested continuance based on the following.

1. At approximately 5:01 pm on March 29, 2023, Luc A. Despins (the "Trustee") filed his Emergency Request for Additional Status Conference (ECF No. 1613, the "Request"), requesting a status conference to discuss issues related to, *inter alia*, the Lady May, the Lady May II, and the Trustee's intention to seek summary judgment in a related adversary proceeding.

2. As stated in the Trustee's Request and upon information and belief, the Lady May II is presently located at a storage facility in Mamaroneck, NY. Upon further information and belief, the Lady May II is a "chase boat" and its purpose is primarily to transport passengers between the Lady May and the shore. The existence of the Lady May II was disclosed to Pacific Alliance Asia Opportunity Fund, L.P. and the Official Committee of Unsecured Creditors at the inception of the Ho Wan Kwok's (the "Debtor") bankruptcy case. Further, an invoice from the Cayman Registry regarding the Lady May II was previously provided to the Trustee. *See* ECF No.

1216-1, at 20. In addition, the Trustee's counsel asked the Debtor about the Lady May II during his deposition on March 2, 2023. This is not new information.

3. At approximately 9:47 am on March 30, 2023, this Court issued its Order Granting Emergency Request for Additional Status Conference and Requiring Appearance of Counsel (ECF No. 1615, the "Order"), which granted the Trustee's Request and scheduled the Status Conference for 1:30 pm on March 30, 2023. This Court's Order further requires that "Attorney [Lee] Vartan and Local Counsel from Zeisler & Zeisler shall appear at the Emergency Status Conference."

4. Attorney Vartan is at Disney World with his children today, March 30. Consequently, Attorney Vartan cannot appear at the Status Conference today upon less than four hours' notice.

5. Therefore, HK USA and Ms. Guo respectfully request that this Court continue the Status Conference to any time on March 31, 2023, when Attorney Vartan will be available to appear before this Court and thereby enable Attorney Vartan to comply with this Court's Order.

6. The Trustee objects to the continuance of the Status Conference.

**WHEREFORE**, for the reasons set forth herein, HK USA and Ms. Guo respectfully

request that this enter an order continuing the Status Conference to March 31, 2023.

Dated this 30th day of March, 2023.

HK INTERNATIONAL FUNDS INVESTMENTS (USA) LIMITED, LLC AND MEI GUO

By: */s/ Aaron A. Romney* Aaron A. Romney (ct28144) Zeisler & Zeisler, P.C. 10 Middle Street, 15th Floor Bridgeport, CT 06604 (203) 368-4234 (203) 549-0872 (fax) Email: [aromney@zeislaw.com](mailto:aromney@zeislaw.com) Their Attorneys

## **CERTIFICATE OF SERVICE**

I hereby certify that on this 30th day of March, 2023, a copy of foregoing was filed electronically. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice ofElectronic Filing. Parties may access this filing through the Court's CM/ECF System.

> By: */s/ Aaron A. Romney* Aaron A. Romney (ct28144)